FOOTBALL'S SOCIAL RESPONSIBILITY - TIME FOR ACTION - BEFORE, DURING AND AFTER THE FIFA WORLD CUP IN QATAR

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FOOTBALL’S SOCIAL
 RESPONSIBILITY
   – BEFORE, DURING AND AFTER
   THE FIFA WORLD CUP IN QATAR
        TIME FOR ACTION
Contents
Introduction                                                                                  3
Summary                                                                                       4
          The Commission’s recommendation concerning a boycott                                4
          The Commission’s recommendations for demands that FIFA take action to improve the
          situation in Qatar and avoid future sports-washing                                  5
          The Commission’s recommendations concerning the need to strengthen the platform
          underpinning NFF’s human rights activities                                          6
Human rights and labour rights challenges linked to the World Cup in Qatar                    7
How NFF can contribute to permanent change in Qatar and FIFA                                  9
          NFF and FIFA’s duty to contribute to permanent change in Qatar                      9
          NFF must work for permanent change within FIFA                                      11
How NFF can combat sports-washing in football                                                 12
Need to strengthen NFF’s platform for working with human rights                               13
Recommended initiatives to effect change                                                      16
          Boycott                                                                             16
          Dialogue and demands                                                                19
          On-site demonstrations                                                              19
With the Extraordinary Congress into the future                                               20
Timelines for developments in Qatar, FIFA and NFF from 2010 to 2021                           21
The Commission’s members                                                                      30
The Commission’s mandate                                                                      30
Plenary meetings of the Commission                                                            32
Reports/sources/interview list                                                                32
1. Introduction
The Commission considers that the FIFA World Cup (World Cup) should never have been awarded to Qatar
in 2010. With this as its starting point, the Commission has been surprised that neither NFF nor FIFA has been
willing or able to quickly and clearly demand that the competition’s organisers and the Qatar authorities ensure
improvements in the situation for migrant workers in the country. FIFA has adopted a new policy intended to
ensure that human rights and labour rights are upheld going forward, but they have not lived up to these standards
with respect to taking responsibility for improving the situation for workers in Qatar. The absence of adequate
action in solidarity with migrant workers has for a long time been a collective failing on the part of the international
footballing community.

The immense international attention surrounding the World Cup has contributed to international pressure for legal
reforms in Qatar. For the Commission, it has been important to illuminate how Norwegian football can contribute
to the World Cup being used to implement these reforms so that they will benefit as many migrant workers as
possible, as effectively as possible.

The Commission has sought to bring together relevant information and, on this basis, arrive at recommendations
which NFF’s Extraordinary Congress must now discuss and vote on. The objective is that this report will assist the
sport’s elected representatives to decide how best Norwegian football can help international football to take
greater responsibility before, during and after the 2022 World Cup in Qatar. The Commission has interpreted the
mandate it was given by NFF’s governing board to mean that we, in this report, should provide the Extraordinary
Congress with a basis for deciding:

1. What is the problem with awarding the World Cup to Qatar, and what do we want changed?
2. Initiatives to succeed in achieving the desired changes.
3. How to avoid “sports-washing” and strengthen Norwegian football’s platform for human rights compliance
   and enhancement.

For the Commission, it has been important to see how Norwegian football can in future strengthen its engagement
to prevent football being misused for political whitewashing, and instead exploit its full potential as a positive force
for Norway and the international community.

Given the relatively short time between the Commission started its work and the report was due to be delivered to
NFF’s governing board and its Extraordinary Congress, the Commission decided to break into working groups with
specific tasks to achieve the most effective collection and processing of relevant information. In addition to various
working group meetings, the full Commission has met 18 times.

The award of the World Cup to Qatar has prompted national and international debate, with strong views being
expressed. In its endeavours, the Commission has sought to be fact-based, but some of the recommendations
inevitably rest on subjective assessments. This is particularly evident in the recommendations concerning the
initiatives Norwegian football must implement to reach the objectives that the Commission is agreed on.

As for most football matches, the outcome of sports diplomacy is uncertain. Just as in football, success depends
on thorough preparation, competence, good judgement and helping each other to play well. In its assessments,
the Commission has emphasised the importance of proposing measures that encourage as many as possible to
concerted action. In sports diplomacy, going it alone quickly descends into empty posturing.

The Commission hopes that it will be possible to bring Norway’s whole sporting community together in support
of a shared platform and shared goals with respect to these ethical issues. Norwegian sports have a total of 250
representatives in international positions, but they lack a unified understanding of what our international efforts
should achieve.

In conclusion, the Commission would like to pay tribute to the individuals who have taken the initiative to put this
debate high on the national and international agenda. You have made a vital difference and have helped make
human rights an integral part of football and not a separate issue that sport can influence from the outside. Now
it is up to the democratic process and NFF’s Extraordinary Congress to decide which ethical choices Norwegian
football shall make. Choices which will have an impact for a long time to come and far beyond Norway’s borders.
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2. Summary
The Commission’s recommendation concerning a boycott
A majority of the Commission, comprising 12 of 14 members, considers that boycotting the World Cup would
not be the most effect way of strengthening human and labour rights in Qatar. Nor would a boycott be the most
effective way of persuading FIFA to introduce permanent changes to promote greater respect for human rights.
This view is based on a review of the facts, interviews and expert assessments.

The majority rests its conclusion on the fact that while there is little likelihood that a boycott would contribute
to permanent changes in either Qatar or FIFA, there is a risk that it could cause Norwegian football to lose
opportunities to exert its influence at a time when international football’s ethical foundations are under pressure.

The majority gives weight to statements by international human and labour organisations asserting that further
dialogue, with clear demands, is necessary for the reforms to be implemented and benefit all migrant workers.

The Commission’s majority therefore recommends that NFF’s Extraordinary Congress vote to send a clear
message to FIFA and the organisers in Qatar demanding the implementation of the important reforms that will
ensure all migrant workers in Qatar a working environment that is neither dangerous nor injurious to their health,
as well as acceptable pay and living conditions. The majority considers that this is important to help ensure the
reforms adopted in Qatar are implemented, which should be a precondition for the entire international football
community’s participation in the World Cup.

The Commission’s majority points out that it is the responsibility of NFF’s governing board to implement the
decisions taken by the organisation’s Annual Congress. The majority considers that the NFF Ethics Committee
will be an important factor in verifying whether Congress decisions regarding human rights activities have been
satisfactorily implemented by NFF. Through dialogue with the major international human and labour rights
organisations with a presence in Qatar, the committee will also be able to assess the situation in the country on an
ongoing basis. Important indicators will be:

• That the workers’ demands are met, including the payment of accrued wages.
• That members of the free press are permitted to enter the country.
• That the implementation of the reforms intended to strengthen migrant workers’ rights in Qatar are not
  reversed.

The Ethics Committee must submit written quarterly reports to NFF’s governing board, which must publish it on
www.fotball.no. The Ethics Committee must also report on its assessment of NFF’s human rights activities at each
Annual Congress, starting in March 2022.

Given the highly censurable and insecure situation for migrant workers in Qatar, commission members Kjersti
Løken Stavrum and Tom Høgli consider that a separate assessment of conditions in the country must be made
immediately prior to the start of the FIFA World Cup Qatar 2022 tournament. The risk of new revelations of
censurable conditions in the run-up to December 2022 is very real. These members consider that this could cause
further embarrassment to the World Cup tournament itself and the wider football community. Given the weakness
that FIFA and NFF have hitherto exhibited, and therefore the lack of confidence in their efforts going forward, it
is natural that the Ethics Committee should lead this assessment and submit its conclusions in a publicly available
report shortly before the tournament begins.

A minority of the Commission, comprising two of its 14 members, want NFF’s Extraordinary Congress to vote in
favour of boycotting the World Cup if it takes place in Qatar. If the tournament is relocated to another host country,
where systematic and gross human rights violations have not been documented, Norway will take part if we
qualify. It is important that Norway does not accept the use of football to legitimise the abuse of human rights and
violation of football’s values, or whitewash dictatorships.

Norwegian football has an independent responsibility to stand up for what is right. There are limits to what
Norwegian football can a participant in. The minority considers that neither Qatar nor FIFA have implemented
changes good enough to make it morally defensible to participate in the tournament if it takes place in Qatar. The

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minority consider that there are no indications that Qatar will succeed in, or is willing to, implement good enough
changes for us to consider it acceptable to participate in the World Cup in Qatar. The minority considers it clear
that the reforms adopted in Qatar have not been implemented on the ground. The minority disagrees with the
majority’s view that a boycott would place Norway on the sidelines with respect to changes in FIFA. The minority
view a boycott as the most powerful weapon we have and will attract massive international attention. It is their
opinion that a boycott could therefore help to demand a new standard for what football can accept both within
FIFA and outside it.

The minority finds it worrying to experience that, step by step, international football is moving its ethical position
away from what should be our moral standards. They find that workers’ rights are particularly poor, while financially
strong actors have their interests enhanced. The 2022 World Cup and the European Super League are examples of
incidents where money and powerful people are able to shape football to far too great an extent. That is why the
protests against the 2022 World Cup send a clear message that enough is enough. That is why it is now vital that
Norway takes a clear stand and sets the political agenda for international football going forward.

The Commission’s recommendations for demands that FIFA take action to improve the
situation in Qatar and avoid future sports-washing
The award of the World Cup to Qatar challenges football’s ability to take its social responsibility seriously. Many
migrant workers in Qatar live and work under unacceptable conditions. According to international labour rights
organisations, the biggest challenges in Qatar today relate to construction sites that are not part of the World Cup
infrastructure programme. Nevertheless, the Commission considers that football has a responsibility to extend the
standards applicable to World Cup-related building work to the whole of the construction industry and other parts
of working life in Qatar. Since 2010, the authorities in Qatar have adopted important reforms, which are intended
to help achieve this. However, international human and labour rights organisations agree that the challenge going
forward lies in the implementation of these reforms.

For a long time, FIFA’s view was that they had no responsibility for working conditions linked to the construction of
stadiums in host countries. In 2015, a complaint was filed against FIFA in Switzerland, under the OECD’s established
grievance procedure, citing abuse of migrant workers’ rights in Qatar. This was the start of a great many changes
in FIFA’s policies. These included adoption of a human rights policy and changes in the criteria for the award
of championship competitions. Clear criteria for the award of competitions, as well as procedures to secure
compliance therewith, are a necessary precondition for the prevention of sports-washing. In 2016, FIFA decided to
include an article on human rights in its Statutes, and announced that human rights would be integrated into the
criteria for the award of the 2026 World Cup.

An important initiative that FIFA implemented in the period 2017–2020 was the establishment of an independent
advisory committee on human rights. The committee’s final report set out important recommendations for FIFA’s
further endeavours, and the Commission has attached importance to these in its own assessment.

  The Commission expects that NFF will:
  • Immediately contact FIFA when NFF becomes aware of serious new incidents in Qatar. NFF must ask FIFA
     to exert its influence with the Supreme Committee and the authorities in Qatar to achieve the fastest
     possible change.
  • Ask FIFA to engage with the authorities in Qatar to secure the establishment of enhanced inspection
     mechanisms to enable abuses against workers to be quickly uncovered and stopped.
  • Be more explicit in demanding that FIFA actively takes responsibility for ensuring that the workers who are
     building stadiums and other World Cup-related infrastructure in Qatar receive what they are entitled to.
     FIFA should also use its influence generally on behalf of migrant workers in Qatar. This includes efforts to
     establish the right to unionise.
  • Support the start-up of a resource centre for migrant workers, which is currently being established, by
     contributing initial capital. NFF should strongly encourage FIFA to do the same.
  • Demand that the authorities in Qatar implement adequate measures to ensure that members of the
     LGBTQI+ community feel welcome and safe as participants or guests during the World Cup.
  • Demand that FIFA incorporate a permanent, independent human rights committee as a key part of the
     FIFA organisation, with members nominated by internationally recognised human rights organisations. In
     addition, a greater focus on independence is crucial in connection with nominations to all independent
     bodies in FIFA.

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•   Secure a binding assurance from FIFA that the award criteria adopted in 2016 will apply to all future FIFA
      championship competitions, for men and women and at the club level. NFF should also work for the
      adoption of a provision that future awards will be withdrawn if host countries fail to meet specific demands
      for change within a specific timeframe.
  •   Ask FIFA to demand a guarantee from the authorities in Qatar that members of the free press will be
      allowed to enter the country and access the facilities before, during and after the World Cup. This is
      particularly important to verify the quality of the information and follow-up of conditions in the country,
      and involves easy access to a visa for any journalist who wants one.
  •   Demand that FIFA issues quarterly reports to all football associations about the preparations for the
      competition, with clear performance indicators.
  •   Invite the Norwegian Olympic and Paralympic Committee and Confederation of Sports to engage in an
      inclusive process to agree on how we can jointly build and rebuild trust in sport’s international ethical
      foundations through tangible steps and measures to prevent sports-washing and help to strengthen
      human rights.

The Commission’s recommendations concerning the need to strengthen the platform
underpinning NFF’s human rights activities
The Commission finds that there is remarkably little focus on human and labour rights in general in the work
NFF does, despite the wide international network that Norwegian football is part of. There is a considerable risk
that national teams and clubs play matches or hold training camps in countries where there are serious human
rights challenges. It is therefore astonishing that NFF does not seem to have a stronger focus on due diligence
methodology and risk analysis. Norwegian football’s efforts to boost respect for human rights must permeate all
levels in the organisation, but the greatest responsibility lies with its leadership.

The Commission considers that NFF’s leadership will in future have to have a stronger focus on how it can give
Norwegian football interests greater impact in UEFA and FIFA. If Norway is to have legitimacy and power in the
international effort to influence FIFA, UEFA and other associations, the Commission believes it is important that
Norwegian football adopts guidelines for how Norwegian football, in the form of its associations, leagues, clubs
and leaders, should address issues relating to human rights.

The Commission will also recommend a review of the Ethics Committee’s mandate and function, to give it
responsibility for verifying that the measures NFF’s Annual Congress adopts to strengthen its human rights
activities are actually implemented. The Ethics Committee should also be given responsibility for reporting to NFF’s
Annual Congress on developments in Qatar and whether necessary reforms there are being reversed.

  The Commission expects that NFF will:
  • Put endeavours to promote human rights far higher on its own agenda. This means, for example,
     embedding respect for human rights as a key aspect of Norwegian football’s international interests in
     NFF’s strategy. Work on this topic must also been reported to the Annual Congress and included in the
     annual report.
  • Develop a comprehensive strategy for how Norwegian football can strengthen its own participation in and
     ability to influence international forums and committees, in order to increase acceptance of Norwegian
     football’s priorities, particularly work to promote human rights, participation and equality, and to combat
     sports-washing and corruption. NFF should establish a committee to propose guidelines for Norwegian
     football on matters relating to human rights.
  • Review the Ethics Committee’s mandate and function, and give it responsibility for verifying that the
     human rights-related measures adopted by NFF’s Annual Congress are actually implemented. This means
     reporting to the Annual Congress on the implementation of decisions, starting with the Annual Congress
     in 2022. To ensure the Ethics Committee has the capacity and competence needed to perform this
     additional task, the Commission urges the forthcoming Extraordinary Congress to consider a resolution to
     increase the Ethics Committee’s membership.
  • Become a member of the UN Global Compact and work for FIFA to do the same.
  • Ensure that NFF acts as a “responsible consumer” in connection with Norwegian participation in
     international events, by choosing suppliers who can demonstrate that they are working actively to avoid
     involvement in gross human rights and/or labour rights abuses.

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•   Introduce procedures to offer players and support staff linked to national and club teams a thorough
     introduction to the human rights situations prevailing in the countries they are going to visit, to build trust
     and pave the way for informed, individual choices concerning, for example, the exercise of free speech.

3. Human rights and labour rights challenges linked
to the World Cup in Qatar
 Link to background memo on working conditions in Qatar

 BWI
 The Building and Wood Workers’ International (BWI), is an international labour organisation that promotes the
 interests for workers in the construction and wood-processing industries. BWI is made up of 351 trade unions
 representing 12 million members in 127 countries. BWI has been working inside Qatar to improve migrant
 workers’ living and working conditions since 2010.

 Labour rights
 Protecting human rights, including labour rights, is primarily the responsibility of the state. This is established
 in international law through a series of conventions, agreements that states choose to sign up to or not.
 Compliance is meant to be secured by the states adopting laws and establishing courts and authorities that
 work to protect human rights. These rights are not restricted to the state’s own citizens, but apply to everyone
 inside its territory. Members of the International Labor Organization (ILO) have decided that when a state
 becomes a member of the ILO, it is automatically bound by all eight of the ILO’s core conventions (on child
 labour, forced labour, freedom from discrimination, freedom of association and collective bargaining). Qatar is
 a member of the ILO.

 The most important measures introduced in Qatar since 2015
 The most important measures introduced by the authorities in Qatar since 2015 are:
 • “The Domestic Workers Law”, which limits working hours and mandates daily rest breaks, one day off a
    week and paid holiday.
 • More than four workers are no longer permitted to be accommodated in the same room.
 • Labour Committees have been established to resolve work-related disputes and increase workers’
    protection under the law.
 • The introduction of fines and prison sentences for the withholding of wages (wage theft), as well as a fund
    to support and accelerate the payment of unpaid wages.
 • A non-discriminatory new minimum wage (to be implemented in 2021).
 • The adoption of legislation to remove the most problematic and restrictive aspects of the kafala system,
    including the requirement that workers obtain exit permits and no-objection certificates if they wish to
    change to a new employer.
 • Ratification of two key international human rights conventions, even though Qatar has reserved the right
    to ignore some of their key obligations, including the right of workers to form and join trade unions.
 • The adoption of new legislation to ensure workers are better protected from heat stress during the
    summer months.

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The kafala system
  The kafala system is used in the Gulf states to control migrant workers, primarily in the building and
  construction sector. The system requires all unskilled workers to have a sponsor in the country, usually the
  employer, who is responsible for visa matters and the workers’ legal status. This system has been fiercely
  criticised by human rights organisations as exploitative because employers can confiscate workers’ passports
  and exploit them with very little risk of legal consequences.

FIFA’s 2010 decision to award of the World Cup to Qatar has been criticised particularly on the grounds that legal
protections in the country are inadequate, that the award was not based on sporting criteria and that it was part
of a “sports-washing” effort to boost Qatar’s standing in the eyes of the world. It has also been alleged by various
media that corruption was involved in the award.

The Commission has examined conditions relating to the construction of the World Cup venues and other
competition-related infrastructure. In the opinion of the Commission, conditions at these sites are better than in
the rest of the country. The authorities in Qatar assert that there were 37 fatalities directly linked to the construction
of World Cup stadiums in the period 2010 to 2019, 34 of which were recorded as not work-related.

Conditions for migrant workers in Qatar were highlighted by The Guardian newspaper in an article published
in February 2021. Here, the total number of migrant workers who have died in Qatar in the same period was
estimated at 6,500. Medical experts have pointed out that the large number of non-work-related deaths ascribed
to cardiopulmonary disease among young men is probably due to fatal heat stroke caused by working in high
temperatures, and that such deaths are therefore linked to the censurable conditions in which many workers live
and toil.

It is unfortunate that a number of different figures for work-related deaths are being circulated, and that they
do not provide a basis for comparison with other countries and situations. The ILO’s statistics for 2020 indicate
that there were 43 work-related deaths in Qatar in a 10-month period. This figure is considerably lower than The
Guardian’s claim, though it is substantially higher than the figure stated by the authorities in Qatar.

Human Rights Watch, Amnesty International and the UN, through the International Labor Organization (ILO),
are among those who have repeatedly warned of censurable conditions for many migrant workers in Qatar. This
includes long-hours and demanding work at dangerously high temperatures, low or missing wages, failure to
recognise trade unions, and poor living conditions. In addition, the workers have been subject to the so-called
kafala system, like other migrant workers in the Gulf region. This system prevents them leaving the country or
changing jobs, without first obtaining their employer’s permission. These challenges are reinforced by the fact that
migrant workers make up approx. 99 per cent of the workforce in Qatar’s construction industry. The Commission
has found that the legislative amendment giving workers the right to change their employer has had an impact.
Since the law went into effect in September 2020, over 70,000 people have made use of this right, according to
official figures. The ILO confirms that a large number of employees who have changed jobs since the change in the
law. Even though this must be considered an indication of extreme discontent, such job swaps create a powerful
incentive for employers to treat their workers well – to secure continuous operations and prevent costly employee
churn. In this way, the competition for workers generates positive change.

The Commission recognises that Qatar has introduced tangible measures and important legislative changes to
improve conditions for migrant workers and abolish the kafala system. Nevertheless, it considers that there is a
long way to go before this has been implemented nationwide, as organisations like Amnesty have underlined. The
need for enhanced implementation is also emphasised strongly by the World Cup organiser in Qatar (Supreme
Committee).

The Commission has given weight to BWI’s reports that international efforts to influence the World Cup organisers
have produced results, and that inspections have confirmed improvements in health and safety at the stadiums.
Deaths linked to the construction of the World Cup stadiums are therefore far lower than in Qatar as a whole.
This confirms BWI’s conclusion that the World Cup organisers have secured better working conditions for migrant
workers than is the standard in the rest of the country. At the same time, the Commission would like to point
out that both the organiser and FIFA must take responsibility for the conditions experienced by migrant workers
engaged in the construction of other World Cup-related infrastructure.

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Although the biggest challenges in Qatar relate to construction sites that are not part of the World Cup
programme, the Commission considers that football and FIFA have a broader social responsibility. Several of the
Commission’s recommendations to NFF’s Extraordinary Congress are therefore measures that are intended to
“transfer” the standards applying to World Cup-related construction projects to the entire construction industry
and other parts of Qatar’s working life.

In the face of this challenge, it is reassuring that BWI, ILO, the International Trade Union Confederation (ITUC) and
Amnesty are unanimous not only in their view of the importance of the improvements that have been introduced
in Qatar since the World Cup was awarded, but also in their assessment of the most important challenges
going forward. All the experts that the Commission has talked to have pointed out that implementation of and
compliance with the reforms and improvements that have been initiated to date will be the main challenge going
forward. The Commission wishes to underline that FIFA has both the opportunity and the responsibility to ensure
that these reforms do not remain simply words on a page, but lead to better conditions for all workers in the
country – also after the World Cup’s floodlights have been turned off. This must include a working environment that
is neither dangerous nor injurious to the health of the workers, as well as acceptable pay and living conditions. NFF
must here take a clearer responsibility and work actively with specific initiatives to support the joint international
pressure being brought to bear by actors both within football and outside it.

4. How NFF can contribute to permanent change in
Qatar and FIFA
     Link to memo on FIFA’s processes for compliance and handling human rights challenges

NFF and FIFA’s duty to contribute to permanent change in Qatar

     Organiser of the 2022 FIFA World Cup.
     The Supreme Committee for Delivery and Legacy (SC) was created in 2011, and is responsible for planning the
     tournament on behalf of Qatar. This includes building stadiums and other necessary infrastructure. One aspect
     of the SC’s responsibility is to ensure that the first World Cup in an Arab country leaves behind the impression
     of a region characterised by a sustainable economy, education and social development.

Immediately after Qatar was awarded the 2022 World Cup, the international trade union movement became
involved and issued five specific demands for Qatar’s continued staging of the tournament:

1.    Abolition of the kafala system
2.    Respect for trade union rights
3.    Introduction of a minimum wage
4.    Introduction of a mediation service
5.    Cooperation with responsible international recruitment agencies

The trade union movement’s objective was to bring about permanent change in the entire country, though its
initial focus was on cooperation with the World Cup organisers. After more than two years of negotiation, a
Memorandum of Understanding (MoU) was signed in November 2016 between the Building and Wood Workers’
International (BWI) and the Supreme Committee (SC) organising the competition. The agreement gave the BWI the
right to perform health and safety inspections at the building sites. BWI’s entitlement has gradually been expanded
to cover more general labour rights.

For a long time, FIFA’s view was that they had no responsibility for working conditions during the construction of
stadiums in host countries. The turning point came in 2015, when a complaint was filed against FIFA in Switzerland,
under the OECD’s established grievance procedure, citing abuse of migrant workers’ rights in Qatar. This is an
example of how FIFA’s policies have been altered in several key areas following external pressure.
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In January 2020, FIFA and the competition organiser in Qatar, World Cup Qatar 2022 LLC (Q22), launched a joint
plan to prevent human and labour rights abuses before, during and after the 2022 World Cup. Under this plan, FIFA
will ask critical questions, while the SC and Q22 are the entities that will actively implement the policies by setting
standards for suppliers, as well as monitoring and dealing with non-compliant working conditions. An important
part of the plan is the mapping of risks relating to various deliveries to the 2022 World Cup.

In the Commission’s opinion, FIFA has taken too little responsibility for the conditions experienced by the workers
in Qatar, including those workers directly involved in the construction of the stadiums. Despite the fact that FIFA
is responsible for the tournament, there are grounds to question the extent to which the positive changes made
on behalf of migrant workers can be ascribed to FIFA. Instead, changes seem to have occurred primarily at the
initiative of the Supreme Committee in Qatar following pressure from the international community.

The Commission finds it extremely unfortunate that NFF’s senior leadership endorsed the award to Qatar in 2010,
and that it was not until 2013 that NFF first expressed concern about the lack of respect for human and labour
rights in Qatar. The Commission wishes to underline that although the resolution passed by NFF’s governing board
in 2016 concerning collaboration with the Norwegian Confederation of Trade Unions (LO) and the Norwegian
Ministry of Foreign Affairs in order to influence migrant workers’ conditions was important, it came too late. The
Commission also considers that NFF could and should have been clearer in its demands to FIFA. The strategy of
working closely with Nordic counterparts to exploit the contacts others have with UEFA and FIFA was correct, but
also showed that NFF has not given priority to building its own relationships and positions in the past decade.

The Commission considers that NFF, both in conjunction with its Nordic counterparts and in its own clear voice,
must demand that FIFA works actively vis-à-vis the authorities in Qatar to oblige them to implement, continue
and expand the reforms after the World Cup. This will also be important if the positive development in Qatar is
to continue to have a ripple effect in the region, as several of the Commission’s interviewees have pointed out.
To succeed in permanently strengthening human and labour rights, FIFA must contribute actively in a broad and
unified engagement with various international actors, such as Amnesty, the international trade union movement,
the UN and the business community.

  The Commission recommends that NFF:
  • Immediately contacts FIFA when it learns of serious new incidents in Qatar, to request that FIFA exerts
     its influence with the Supreme Committee and the authorities in Qatar to achieve the fastest possible
     change.
  • Asks that FIFA works vis-à-vis the authorities in Qatar to establish enhanced inspection mechanisms to
     quickly identify and stop the abuse of workers.
  • Works to persuade FIFA to demand that the authorities in Qatar improve migrant workers’ legal
     protection through mechanisms that ensure abusive employers are held to account.
  • Challenges FIFA to take further steps to ensure respect for workers’ right to unionise.
  • Supports the start-up of a resource centre for migrant workers, which is currently being established, by
     contributing initial capital. NFF should strongly encourage FIFA to do the same.
  • Demands that FIFA take an active role in helping to ensure that workers engaged in the construction
     of stadiums and other World Cup-related infrastructure in Qatar receive what they are entitled to. This
     means, for example, that FIFA must be kept informed by the Supreme Council of any non-conformances,
     and must follow up the Supreme Committee’s activities with respect to the workers concerned.
  • Asks FIFA to demand a guarantee from the authorities in Qatar that members of the free press will be
     allowed to enter the country and access the facilities before, during and after the World Cup. This is
     particularly important to verify the quality of the information and follow-up of conditions in the country,
     and involves easy access to a visa for any journalist who wants one.
  • Demands that the authorities in Qatar implement adequate measures to ensure that members of the
     LGBQTI+ community feel welcome and safe as participants or guests during the World Cup.

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NFF must work for permanent change within FIFA

  The principle of due diligence
  Since companies often have a huge impact on people’s lives, standards have been established at the
  international level for companies’ responsibilities with respect to human rights. In 1999, the UN Global
  Compact was established. This sets out a number of key principles for companies’ ethical responsibilities,
  which companies can choose to endorse. The UN and the OECD (which are two intergovernmental
  organisations) have subsequently established a shared framework for how companies (like FIFA) should work
  to ensure that they do not cause or contribute to human rights abuses, including labour rights violations. The
  methodology, which is internationally recognised, builds on the principle of due diligence, and involves a
  continuous process containing five elements: establish a policy; perform a risk assessment to identify where
  in the organisation the risk of serious abuses is greatest; ensure compliance and that incidents that have
  occurred are dealt with; appoint someone in the company to be explicitly responsible for this area; ensure
  that measures and processes are working through regular follow-up. Reports must also be submitted internally
  to the board, while external reporting must describe how the organisation addresses risk, which risks have
  been identified and how they are dealt with. The process is dynamic, in that all the phases are interlinked, with
  changes being made when failings are discovered, and the changes subsequently reported.

FIFA’s criteria for awarding championship competitions have been modified since Qatar was awarded the World
Cup in 2010 (See the section on “sports-washing” in Chapter 5 below). In FIFA’s assessment of Qatar’s application
in 2010, neither human rights nor the risk of human rights abuses was adequately addressed. At that time, the issue
was not on FIFA or Qatar’s radar.

In 2017, FIFA adopted a human rights policy. It is ambitious and builds on the due diligence methodology
recommended by the OECD and UN. The policy has been adopted at the highest level in FIFA and states that
human rights must be an integral part of all processes within FIFA through risk assessment and follow-up, and
that internal structures to ensures this happens will be established. Furthermore, human rights has become a
fixed agenda item for the annual FIFA Congress. Despite FIFA having an established policy and award criteria that
protect human and labour rights, it has subsequently awarded other FIFA-related championships without making
any demands. It is important that FIFA, in its future practice, demonstrates a willingness and an ability to implement
these changes.

One of FIFA’s most operative measures is that it had an independent Human Rights Advisory Committee in the
period 2017–2020. The committee’s mandate was to work to strengthen FIFA’s efforts to secure respect for human
rights. The now defunct committee comprised eight experts on human rights, labour rights, the protection of
children in sports and the fight against corruption. Committee members were drawn from the UN, trade unions,
academia, civil society and business. The committee published its final report in February 2021, in which it
concluded that FIFA had initiated many important measures during the four-year period. The committee disclosed
that FIFA had acted on 60 per cent of its recommendations and that 40 per cent are, completely or partly, in the
process of being initiated. However, the committee also made several criticisms, including the fact that FIFA had
not included human rights requirements in the award criteria for all championship competitions, but only for the
award of the for men’s and women’s World Cup.

The committee also said that even though FIFA has achieved much in Qatar, there is still a considerable risk of
serious human rights abuses, particularly against migrant workers in the construction sector and other sectors
linked to the World Cup, such as hotel operations, but also with respect to protecting the rights of ticket-holders
and other visitors during the World Cup itself. With respect to the situation facing workers in Qatar, the committee
considers that it takes far too long to give workers the help they need when abusive conditions are discovered.
FIFA should therefore take a more active role to change this.

The Commission would like to point out that even though FIFA has made important changes to the award criteria
and adopted a human rights policy, they have done too little to ensure that these new standards have any kind
of retroactive effect. FIFA should have assumed a far greater responsibility for ensuring that all migrant workers
directly or indirectly associated with the World Cup preparations receive what they are entitled to. Nor, in the
Commission’s opinion, has FIFA used the opportunities the competition affords to make unqualified demands
that the authorities in Qatar fully implement the adopted reforms for the benefit of all the migrant workers in the
country.
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The Commission expects that NFF will:
  • Demand that FIFA incorporate a permanent, independent human rights committee as a key part of the
     FIFA organisation, with members nominated by internationally recognised human rights organisations
     and other relevant and independent actors, such as the UN, trade unions, academia, civil society and the
     business community.
  • Work actively to ensure FIFA establishes a system to ensure transparency and independence in connection
     with nominations to all independent bodies in FIFA.

5. How NFF can combat sports-washing in football

  Sports-washing
  The term “sports-washing” is used when a state organises, sponsors or takes ownership of high-profile
  sporting events or sports organisations for the purpose of diverting attention away from conditions for which
  that same state has been heavily criticised. Sports-washing is a tactic that has been and is still used particularly
  by states that commit or permit human rights abuses or crimes against humanity. According to Amnesty,
  sports-washing is really a PR campaign to enhance the country’s international reputation.

An important way of preventing sports-washing is to establish good criteria for the award of championships, as well
as procedures to ensure the criteria are applied. FIFA has listed a great many criteria that countries seeking to host
championships must address. The criteria cover, for example, infrastructure, arena facilities and training camps, as
well as guarantees relating to security, financial matters, etc, from all governing levels. The award criteria contained
no items specifically relating to human rights until May 2016. In other words, the championship that was eventually
awarded to Mexico/USA/Canada was the first in which weight was given to human rights.

In 2016, FIFA decided to include an article on human rights in its Statutes, and announced that human rights
would be integrated into the award criteria for the 2026 World Cup. Applications to host major championships
must therefore now contain an independent report on the applicant country’s human rights situation, with an
assessment of risk, a description of how stakeholders’ views have been taken into account when preparing the
report, and a plan for how human rights challenges in the country concerned will be handled with the approval of
its governing authorities. The human rights aspects detailed in the application documents will then be assessed by
an independent third-party before FIFA’s members proceed to a vote.

In connection with the 2018 award of the World Cup to Canada/Mexico/USA, these procedures were followed,
and the process showed that the criteria and the intention to carry out a transparent assessment of the applicant
countries’ human rights status worked as intended. The Commission considers that FIFA’s award of the FIFA Club
World Cup to China in 2019 shows the importance of applying the award criteria and procedures adopted for the
World Cup to other types of FIFA-related competitions. FIFA has argued that the short time they had available
in connection with the 2019 award meant that they had to “modernise” the award process through a simplified
and accelerated procedure, where they involved a number of potential “host member associations” before they
concluded by proposing the Chinese Football Association to the FIFA Council meeting. Nevertheless, FIFA
claims that they are retaining human rights requirements both in the award and execution of FIFA championship
competitions, and always expect host countries to guarantee and pledge to uphold human rights in their
tournament-related activities in accordance with internationally recognised human rights standards and FIFA’s
own human rights policy. The Commission points to FIFA’s independent human rights committee which, in its
2020 report, sharply criticised the fact that FIFA did not apply the award criteria demanding documentation of
the potential host country’s human rights situation when it awarded the Club World Cup to China in 2019. The
Commission therefore considers that it is absolutely necessary for the criteria to apply to all types of championship
competition under FIFA’s auspices, and that UEFA and the other confederations introduce the same standards.

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The Commission expects that NFF will:
  • Demand that FIFA commit to following the procedure and award criteria it adopted in 2016 in the award
     of all future FIFA-related championships.
  • Take the initiative to ensure that UEFA’s award criteria and procedures have the same minimum
     requirements as FIFA.
  • Obtain a commitment from FIFA confirming that in all future championships they will draw up detailed
     strategies for the actual execution of the championship. While the award criteria and policy have been
     made permanent in FIFA, the framework for the actual execution applies only to the World Cup in Qatar.
  • Work to ensure that future awards are withdrawn if the host country has not met FIFA’s specific change
     requirements within a specific timeframe.
  • Demand that all championships are predicated on members of the free press being granted entry to the
     country and access to the facilities before, during and after the competition. This must also include Club
     World Cups that have already been awarded.
  • Demand that FIFA issues quarterly reports to all football associations about the preparations for the
     competition in Qatar, with clear performance indicators.
  • Ensure that FIFA’s rules relating to human rights requirements when awarding championships are
     complied with in connection with all votes at the FIFA Congress, and that no championship is awarded
     outside this regime.
  • Invite the Norwegian Olympic and Paralympic Committee and Confederation of Sports to engage in an
     inclusive process to agree on how we can jointly build and rebuild trust in sport’s international ethical
     foundations through tangible steps and measures to prevent sports-washing and help to strengthen
     human rights. This also means that members of the free press must have access to all championships and
     Olympic Games.

6. Need to strengthen NFF’s platform for working
with human rights

  FIFA/UEFA
  FIFA is currently made up of 211 different associations, which are all entitled to attend and vote at the
  annual FIFA Congress, FIFA’s highest decision-making body. The FIFA Council comprises the president
  and 36 members. FIFA also has a number of different committees, the majority of which are appointed by
  the FIFA Council, and where geographic representation plays an important role. While FIFA’s president is
  elected directly by the FIFA Congress, the other members of the Council are appointed by the six different
  confederations. UEFA is the largest confederation, with seven members on the FIFA Council. The most
  effective way for European football associations to attempt to influence FIFA is through UEFA. At the same
  time, the confederations have a large degree of autonomy and are, among other things, responsible for the
  World Cup qualifying competitions.

In its work and strategy, NFF focuses internationally on practical human rights activities, particularly the right of
women and girls to participate in football. The Commission finds that there is remarkably little focus on human
and labour rights in general in the work NFF does, despite the wide international network that Norwegian football
is part of. There is a considerable risk that national teams and clubs play matches or hold training camps in
countries where there are serious human rights challenges. It is therefore astonishing that NFF does not seem to
have a stronger focus on due diligence methodology and risk analysis. The Commission considers that NFF has a
particular responsibility to raise awareness and ensure good routines among all actors in Norwegian football, but
that membership of FIFA also conveys an obligation to work actively vis-à-vis UEFA and FIFA.

Norwegian football’s efforts to boost respect for human rights must permeate all levels in the organisation, but
the greatest responsibility lies with its leadership. This leadership responsibility means building a clear institutional
platform for this type of value-related issues. The NFF’s current strategy contains a chapter entitled “Norway

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will influence football’s development internationally”, in which it states that Norway wishes to play a role in the
development of international football. The importance of promoting the status of women’s football and preventing
any further widening of the gap between the clubs/countries with the greatest resources and the smaller leagues/
nations is particularly highlighted. The Commission will recommend that the strategy plan more clearly describes
Norway’s ambitions as a standard-bearer for human rights, but also equality in football, as well as the fight against
corruption. Such a goal will have considerable legitimacy given the decades-long efforts NFF has made in the area
of development cooperation and women’s right to participate in the Middle East, North Africa, Southeast Asia and
the Balkans. The inclusion of human rights activities in the strategy will be an important factor in raising Norwegian
football’s awareness and ensuring that the governing board and Annual Congress regularly discuss these kinds of
issues. It is unfortunate that at the many Annual Congresses since 2010, Qatar is mentioned only twice, and only
once at the initiative of the governing board.

The Commission considers that NFF’s leadership should in future have to have a stronger focus on how it can give
Norwegian football interests greater impact in UEFA and FIFA both by giving higher priority to its own international
participation and through strategic alliances with other associations. FIFA’s committee structure is extensive, with
many committees comprising representatives from associations worldwide. NFF does not currently have a single
member on any of FIFA’s decision-making committees and bodies. NFF currently has seven representatives on
different UEFA committees. It is worth noting that six of these are men. The Commission considers that NFF should
mobilise to obtain political appointments and positions in both UEFA and FIFA, in order to gain acceptance for
Norwegian football’s interests, as well as secure a correct balance among the holders of all international offices.

It is today’s practice for the NFF’s governing board to nominate representatives to the various international
committees. A mentoring and training programme should be established, which can prepare candidates for
membership of international bodies, including adequate training in how best to promote the human rights
perspective. It must be an explicit objective to obtain positions in UEFA/FIFA, and there must be a specific goal
relating to the proportion of women on international committees and subcommittees. In the Commission’s view
the Nomination Committee must prioritise the proposal of candidates to NFF’s governing board with international
competence, who can represent NFF internationally and promote Norwegian football’s interests. The top clubs
should have similar ambitions and goals with respect to international influence in both the men’s and the women’s
game.

The Commission further recommends that today’s procedures for NFF’s decision to support host countries be
made known, reviewed and, if necessary, revised. A good argument can be made for a broader, democratic process
involving the entire Norwegian football organisation before this type of choice is made. Clear procedures and
transparency surrounding the decision will help raise awareness of and strengthen the importance of the choice of
host venue, and a thorough process and broad support will also give Norwegian football leaders a clearer mandate
in their dialogue with FIFA and FIFA’s members.

If Norway’s efforts to influence FIFA, UEFA and other associations are to have legitimacy and be successful, the
Commission believes it is necessary to start with ourselves. Norway is seen as having a strong value platform and a
wide-ranging humanitarian engagement, with support from the country’s Foreign Ministry. However, we have very
few guidelines for how Norwegian football, its associations, leagues, clubs and leaders, ought to address issues
relating to human rights. Agreement on a platform that Norway’s entire footballing community can get behind
would be extremely valuable.

The Commission therefore proposes that a broadly encompassing committee be set up in the autumn of 2021
to propose an entirely new set of guidelines or “Code of Conduct”, which will address the issues and dilemmas
Norwegian football encounters in the area of human rights. Such a policy document should be presented to the
NFF’s Annual Congress in 2022, and must be seen in light of the similar work that the Norwegian Olympic and
Paralympic Committee and Confederation of Sports is carrying out.

The Commission will also recommend a review of the Ethics Committee’s mandate and function, with an
emphasis on how its real independence can be enhanced. According to its mandate, the committee shall be an
autonomous and independent body, appointed by and reporting to NFF’s Annual Congress. This is important to
secure institutional learning on the part of football’s highest decision-making body. The Commission recommends
that the Ethics Committee be given greater authority. This means having responsibility for verifying that the
measures adopted by NFF’s Annual Congress with a view to strengthening the organisation’s human rights
activities are actually carried out. Such a responsibility includes reporting on developments in Qatar, based on the

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assessments of international trade union and human rights organisations. It will also include reporting on NFF’s
efforts to implement all the decisions taken by the Extraordinary Congress. Reports should be made to all Annual
Congresses and in writing between Congresses. This will require the Ethics Committee to increase its capacity and
competence. The Commission will therefore recommend that NFF’s Extraordinary Congress resolve to increase the
committee’s membership and that the governing board ensures that the committee has sufficient administrative
resources to accomplish its work. In line with NFF’s general principle of transparency, the committee should have
the opportunity to speak freely to the media, as well as publish meeting agendas and those parts of the minutes it
feels should be made available to the wider Norwegian footballing community.

Operating sustainably means taking responsibility for human and labour rights, the climate/environment and
anti-corruption activities. By continuing its work under the UN’s Guiding Principles on Business and Human Rights,
as well as endorsing the UN Global Compact (UNGC), FIFA will commit to including the ten UNGC principles in
its own strategies and action plans. FIFA can report on its efforts within these areas annually through the UNGC.
This will necessitate clear commitments and transparency with regard to their implementation, and FIFA will set a
positive example for other organisations and business entities.

  The Commission expects that NFF will:
  • Make more explicit in NFF’s strategy that respect for human rights is a key aspect of Norwegian football’s
     international interests.
  • Draw up a strategy for how Norwegian football can strengthen its participation and influence in
     international forums and committees, in order to gain acceptance for Norwegian football’s adopted
     priorities, particularly efforts to promote human rights, participation and equality, and to combat sports-
     washing and corruption.
  • Review Norwegian football’s procedures for deciding which candidate to host championship competitions
     NFF should support.
  • Establish a committee to propose guidelines for how Norwegian football should address human rights
     issues. Reviews the Ethics Committee’s mandate and function, and give the committee responsibility
     for verifying the implementation of the measures adopted by the Annual Congress to strengthen NFF’s
     human rights activities. This means reporting to the Annual Congress on the status of implementation,
     initially at the Annual Congress in 2022. To ensure that the Ethics Committee has sufficient capacity and
     competence to undertake these additional tasks, the Commission urges the Extraordinary Congress to
     consider a resolution to expand the committee’s membership.
  • Become a member of the UN Global Compact and work to get FIFA to do the same.
  • Ensure that NFF acts as a “responsible consumer” in connection with Norwegian participation in
     international events by choosing suppliers who can demonstrate that they are working actively to avoid
     involvement in gross human rights and/or labour rights abuses.
  • Introduce procedures to offer players and support staff linked to national and club teams a thorough
     introduction to the human rights situations prevailing in the countries they are going to visit, to build trust
     and pave the way for informed, individual choices concerning, for example, the exercise of free speech.
  • Report to each Annual Congress on human rights activities in general and the follow up of the specific
     human rights-related measures adopted by the Annual Congress in particular.

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